title: Switzerland — Conduct, Safeguarding & Promotions | World Payments Monitor canonical: https://payments.gi/jurisdictions/switzerland/w1b/ publisher: Asymmetric Intelligence ### W1b Conduct, Safeguarding & Promotions limited signal Confirmed confirmed 2026-06-27 Conduct and client-onboarding rules flow from the Financial Services Act (FinSA/FIDLEG) (client segmentation, suitability, prospectus) and AMLA. Safeguarding is not via an EU-style segregation/insurance regime: FinTech-licensed deposits are NOT covered by deposit protection and clients must be warned. The proposed payment instrument institution regime would for the first time require full segregation of client funds from the institution's own assets, with bankruptcy protection and high-quality liquid backing assets. AML onboarding can use digital/video identification under FINMA Circular 2016/7. Financial intermediaries below the FinTech threshold must affiliate with an AMLA self-regulatory organisation (SRO). Standing sub-brief · as of 6 August 2026 124 words · last cycle 2026-09-01 #### Conduct, Safeguarding & Financial Promotions The Federal Council completed implementation of the EU's 19th sanctions package on 26 February 2026, introducing Switzerland's first crypto-asset sanctions prohibition, and partially implemented the 20th package on 22 May 2026, banning RUBx and the digital rouble and extending bans to twenty Russian banks. These measures apply across both bank and non-bank payment institutions rather than being confined to one licence class. SECO published revised interpretive guidance for financial institutions alongside the sanctions amendments, dated 26 February 2026. #### Outlook The 20th sanctions package has so far been only partially implemented, indicating further alignment steps with the EU sanctions regime remain open. No CH-specific financial-promotion enforcement action was identified this cycle, leaving that vector without a dedicated development to report. Periodic update · new data 2026-08-11 #### Conduct, Safeguarding & Financial Promotions Switzerland's conduct and financial-crime-adjacent obligations for payment firms tightened materially this cycle through the sanctions channel rather than through a dedicated conduct-rulebook change. The Federal Council completed implementation of the remainder of the EU's 19th sanctions package on 26 February 2026 and partially implemented the 20th package on 22 May 2026, introducing Switzerland's first dedicated crypto-asset sanctions prohibition, banning ruble-backed stablecoins, RUBx transactions, and digital-rouble transactions from 26 May 2026, and extending transaction bans to twenty Russian banks. This is an assessed finding, corroborated by two independent Tier-3 legal-sector sources, though no Tier-1 primary source was retrieved this cycle. The classification here spans both bank-PSP and non-bank-PI/EMI obliged entities: the prohibition attaches to the transaction and instrument type rather than to a specific licence category, meaning both a bank-chartered PSP and a non-bank payment or crypto institution handling the newly prohibited instruments carry the same conduct obligation to screen for and refuse them. A dashboard-tier item accompanies the sanctions amendments: the State Secretariat for Economic Affairs (SECO) published revised interpretive guidance and an FAQ for financial institutions alongside the amendments, dated 26 February 2026, an assessed finding from a single Tier-3 source. This is logged here as a short, dated development rather than a standalone explainer, consistent with its dashboard content tier: it is implementing guidance accompanying the primary sanctions instrument rather than a separate conduct rule in its own right. The structural significance of the crypto-asset sanctions addition, for conduct purposes specifically, is that it creates a new category of prohibited-instrument screening that most Swiss payment and banking conduct functions did not previously need to operationalise: ruble-pegged stablecoins and central-bank digital currency transactions were not previously named prohibition categories in Switzerland's sanctions conduct obligations. Firms with any correspondent or counterparty exposure to Russian-linked crypto-asset rails now carry a conduct obligation to have screening logic capable of identifying these specific instrument types, a capability that, on the evidence available this cycle, did not previously need to exist in Swiss compliance programmes. No financial-promotions-specific development, and no safeguarding-rule change of the kind seen in other jurisdictions this cycle, was identified for Switzerland this cycle. The conduct-relevant signal here is confined to sanctions-driven screening and transaction-refusal obligations rather than a broader promotions or safeguarding rulebook change. #### Outlook Watch for whether a Tier-1 SECO or Federal Council primary source becomes available to firm this cycle's Tier-3-only sourcing, and for further phased implementation steps as Switzerland continues its typical pattern of mirroring EU sanctions packages with a lag. The 26 May 2026 effective date for the RUBx and digital-rouble prohibitions is the operative near-term compliance deadline for screening systems. **Sources and findings (4)** 1. T3 [https://goldblum.ch/knowledgebase/license-for-the-financial-services](https://goldblum.ch/knowledgebase/license-for-the-financial-services) 2. T1 [https://www.finma.ch/en/authorisation/fintech/fintech-bewilligung/](https://www.finma.ch/en/authorisation/fintech/fintech-bewilligung/) 3. T3 [https://www.legal500.com/guides/chapter/switzerland-fintech/](https://www.legal500.com/guides/chapter/switzerland-fintech/) retrieved 2026-06-27 4. T3 [https://cms.law/en/che/legal-updates/swiss-finma-communicates-its-stablecoin-practice](https://cms.law/en/che/legal-updates/swiss-finma-communicates-its-stablecoin-practice) retrieved 2026-06-27